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Response to EEI's Timeline of Environmental Regulations For the Utility Industry
1. Possible Timeline for Environmental Regulatory Requirements for the Utility Industry Pending EPA air and water pollution regulations for coal plants have been compared to a “train wreck” but this is hardly the case. The timeline below, originally produced by the Edison Electric Institute, primarily consists of procedural events and rules that will not impose a direct compliance obligation on coal units and otherwise serves only to spread confusion about EPA’s actual regulatory schedule. For more information: www.wri.org/eei-timeline-response
2. Environmental Regulatory Requirements For the Utility Industry, Removing All But New Compliance Obligations There are four categories of EPA activity on the EEI timeline that should be removed leaving only the actual compliance obligations: For more information: www.wri.org/eei-timeline-response
3. Regulatory Compliance Obligations for the Utility Industry When only the actual compliance dates of new regulations are presented in the timeline, it becomes apparent that the EPA’s regulatory process is clear and the utility industry has adequate time to prepare for pending compliance obligations. For more information: www.wri.org/eei-timeline-response
Editor's Notes
See page 3 of the “An Exchange on Change” Edison Electric Institute, 2010. http://www.eei.org/magazine/EEI%20Electric%20Perspectives%20Article%20Listing/2010-09-01-EXCHANGE.pdf
Note: If states believe that the only way to come into attainment of NAAQS standards is by obtaining additional reductions from electric generators, then the most likely way for states to effect those changes is through modification of the existing regulations that already control emissions of those same pollutants. EPA could undertake similar action through a future update to the Transport rule.